ANDY ANG V SEVERINO PACUNIO ET AL.

GR NO. 208928, JULY 8, 2015

 ANDY ANG, Petitioner, v. SEVERINO PACUNIO,
TERESITA P. TORRALBA, SUSANA LOBERANES,
CHRISTOPHER N. PACUNIO, AND PEDRITO P. AZARCON,
REPRESENTED BY THEIR ATTORNEY-IN-FACT,
GALILEO P. TORRALBA, Respondents. 
 FACTS OF THE CASE:

▪ This case arose from a complaint over a parcel of land originally owned and
registered under Felicisima Udiaan who died on December 15, 1972, and left the
subject land as inheritance to her heirs.
▪ It was sold to petitioner Andy Ang on July 12, 1993 from a person representing herself
as Udiaan, who showed community tax certificate as proof of identity, has in her
possession Original Certificate of Title, knew the location of the land and executed
Deed of Absolute sale before the notary public.
▪ Petitioner contends that he bought the land in good faith and for value without any
knowledge or participation to any of its alleged defects.
▪ Certificate of Title was issued under the petitioners name and used the same land for
his livestock business.
 FACTS OF THE CASE:

▪ Respondents Severino Pacunio, Teresita Torralba, Susana Loberanes, Christopher

Pacunio, and Pedrito Azarcon alleged that they are the grandchildren and successors-
in-interest of Udiaan.
▪ Respondents were never in possession of the same land nor paid for its real property
taxes. A portion of such land was occupied by Heirs of Gaccion and petitioner bought
the same land anew to buy peace.
▪ Respondents contends that the petitioner could not have validly acquired the subject
land since Udiaan could not have validly sold the same considering she was already
dead for more than 20 years when the sale occurred.
▪ The Respondents pray for the Declaration of Nullity of Sale, Reconveyance, and
damages.
THE RTC RULING

▪ RTC ruled in favor of the Petitioner and dismissed the case for lack of
merit.
▪ It found that the respondents claiming to be successors-in-interest
over the subject land failed to prove the same.
▪ RTC concluded that respondents are not the real parties in interest to
institute an action against petitioner, warranting the dismissal of
their complaint.
THE CA RULING

▪ The CA modified and affirmed the decision of the RTC.

▪ Nullified the questioned Deed of Absolute Sale since it is clearly
executed by a person other than Udiaan.
▪ Declared valid sale between petitioner and heirs of Gaccion
▪ Distributed portions of the subject land to the Heirs of Gaccion and
the children of Udiaan.
▪ Affirmed the RTC’s ruling that respondents are not a real party in
interest to the instant case being a mere grandchildren they does not
have successional rights to Udiaans estate unless their mother
predeceased Udiaan which fact was not established.
 ISSUE:

▪ Whether or not the Respondents who are claiming to be the

grandchildren and successor of interest of Udiaan are the real parties in
interest to institute an action against the petitioner.

No. The court ruled that the respondents are not the real parties in interest in this
instant case.
SUPREME COURT RULING:

▪ Rule 3 Section 2 of the Rules of Court - Parties to civil action provides:

▪ SEC. 2. Parties in interest. - A real party in interest is the party who
stands to be benefited or injured by the judgment in the suit, or the
party entitled to the avails of the suit. Unless otherwise provided by
law or these Rules, every action must be prosecuted or defended in
the name of the real party in interest. 
▪ Parties in Interest has 2 requirements:
▪ 1. to institute an action, the plaintiff must be the real party in interest;
▪ 2. the action must be prosecuted in the name of the real party in
interest.
 ▪ Interest means a material interest or an interest is issue to be
affected by the decree or judgment of the case.
▪ For such right to be available to the respondents, they would have
shown that their mother:
▪ A. predeceased Udiaan;
▪ B. is incapacitated to inherit;
▪ C. was disinherited, if Udiaan died testate.
Necessarily, the purposes of this provision are
1) to prevent the prosecution of actions by persons without any right, title or interest in the case;
2) to require that the actual party entitled to legal relief be the one to prosecute the action;
3) to avoid multiplicity of suits; and
4) discourage litigation and keep it within certain bounds, pursuant to public policy. 
▪ Nothing in the records would show that the right to representation is
available to the respondents, the proper cause of action was for the
CA to merely affirm the RTC’s dismissal of their complaint.
▪ When the plaintiff is not the real party in interest, the case is
dismissible on the ground of lack of cause of action.
▪ CA erred in granting one of the principal reliefs sought by the
respondents, which is the declaration of the nullity of the Questioned
Deed of Absolute Sale.
▪ CA also erred in awarding portions of land to various non-parties to
the case.
▪ In sum, the CA transgressed prevailing law and jurisprudence in
resolving the substantive issues of the instant case despite the fact
that respondents are not real parties in interest to the same.
▪ Basic rule also is that no relief can be extended in a judgment to a
stranger or one who is not a party to a case.
▪ The petition is granted in favor of the petitioner, decision of the CA is
reversed and Set aside and decision of RTC is reinstated.
▪ Therefore, the petition is dismissed for the respondents have not
been able to prove that they are the real parties in interest to nullify
the Deed of Absolute Sale between Andy Ang and Felicisima Udiaan.
THANK YOU